Preview
FILED
TARRANT COUNTY
8/20/2020 3:59 PM
360-687378-20 THOMAS A. WILDER
DISTRICT CLERK
JASMIN J. JULIEN § IN THE DISTRICT COURT
§
V. § JUDICIAL DISTRICT
§
EDWARD J. BROOKS § TARRANT COUNTY, TEXAS
PETITION TO ENFORCE FOREIGN JUDGMENT
This Petition to Enforce Foreign Judgment and the attached foreign judgment and
declaration are filed under the Uniform Enforcement of Foreign Judgments Act, chapter 35 of
the Texas Civil Practice and Remedies Code, by Jasmin J. Julien, Petitioner. The last three
numbers of Petitioner's Social Security number are 685.
1. Discovery in this case is intended to be conducted under of rule 190 of the Texas
Rules of Civil Procedure.
2. A properly authenticated copy of the Consent Judgment isattached as Exhibit A
and is entitled to full faith and credit.
3. The Consent Judgment is final and not subject to modification.
4. Respondent, Edward J. Brooks, has agreed that the child may move to Texas, and
Petitioner seeks enforcement.
Petitioner prays that this judgment of the 24th Judicial District Court for the Parish of
Jefferson of the state of Louisiana be accorded full faith and credit and have the same effect as a
judgment of this Court.
Respectfully submitted,
DWAIN DOWNING
1178 W. Pioneer Parkway
ARLINGTON, TX 76013
Tel: (817) 860-5685
Fax: (817) 916-8804
By: ~(
Dwainowning
~(2k4 IC
J\
State Bar No. 06086550
downingoffice@aol.com
Attorney for Jasmin J. Julien
Supporting Declaration
1. My name is Dwain Downing. I am above the age of eighteen years, and I am
fully competent to make this declaration. The facts stated in this declaration are within my
personal knowledge and are true and correct.
2. The last known post office address of Edward J. Brooks is 3300 Dickens Dr.
New Orleans, LA 70114.
3. The address of Jasmin J. Julien is 3651 Prairie Waters Dr. #3104, Grand Prairie,
TX 75052.
4. The attorney for Jasmin J. Julien is Dwain Downing, 1178 W. Pioneer Parkway,
ARLINGTON, TX 76013.
~
D'ah;Downing
~ /'
' \ ~ ~
Attorney for Petitioner
My name is Dwain Downing, and I am over the age of 18, and my address is 1178 W.
Pioneer Parkway, ARLINGTON, TX 76013, United States. I declare under penalty of perjury
that the foregoing is true and correct.
Executed in Tarrant County, Texas, on--~---+-· _ _ _ _ _J_v_·+-_2.--c __,_'_')..-...)
___
f:-ry- I
____.c.
Dwain Downing, Declarant
24th JUDICIAL DISTRICT COURT FOR THE PARISH OF JEFFERSON
STATE OF LOUISIANA
NO. 752-066 DIVISION "M"
EDWARD BROOKS 0
vs.
t~;,-- FILED ~·-~~
·~t:_ ~~
JAZMINE JULIEN ."~ ~ SEP 14 2015 . :·1
CONSENTJUDGMEN/ ·i~L~
This matter came for hearing officer conference on September 14, 2015 on a motion
for Custody and Visitation filed on July 29, 2015 by Edward Brooks.
PRESENT: Edward J. Brooks, Jr., Self-Represented Litigant
Jasmin J. Julien, erronerously referred to as Jazmine Julien, Self-
Represented Litigant
When after having a conference with Hearing Officer Paul S. Fiascomrro and with the
consent of the parties,
IT IS ORDERED that the parties shall be awarded joint custody of the minor child,
Cadence P. Brooks, with Jasmin J. Julien being designated as the domiciliary parent.
IT IS FURTHER ORDERED that father shall have unsupervised physical custody time
with the minor as follows: alternating every three (3) days beginning September 17, 2015 at
noon.
IT IS FURTHER ORDERED that both parties shall have vacation options with the child
each year. They shall notify each other in writing of their vacation plan on or before thirty (30)
days prior to departure. Each party shall provide the other with a basic itinerary to include travel
dates, destinations and telephone numbers for emergency purposes. Mother and Father shall
each have two (2) week each year/summer.
IT IS FURTHER ORDERED that the parties agree to the following holiday schedule:
New Year Eve In odd years, father will have the minor from noon on the 3 pt until
noon on the 1st .In odd years, mother will have the minor from
noon on the l 51until noon on the 2nd .
New Year Eve In even years, mother will have the minor from noon on the 31st
until noon on the 1st In even years, father will have the minor
from noon on the 1st until noon on the 2nd .
Mardi Gras Even years to mother and odd years to father.
I
Page 1 of 3
Easter/Spring Odd years to mother and even years to father.
July 4th Even years to mother and odd years to father.
Labor Day Odd years to mother and even years to father.
Halloween Even years to mother and odd years to father.
Thanksgiving Day In odd years, Mother will have 8:00 a.m. to 2:00 p.m. and Father
will have 2:00 p.m. to 8:00 p.m. In even years, Mother will have
2:00 p.m. to 8:00 p.m. and Father will have 8:00 a.m. to 2:00 p.m.
Thanksgiving
School Break
Christmas Eve In odd years, mother will have the minor from noon on the 24th
until noon on the 25 1h. In odd years, father will have the minor
from noon on the 25th until noon on the 261h.
Christmas Eve In even years, mother will have the minor from noon on the 25th
until noon on the 26 1h. In odd years, father will have the minor
from noon on the 24th until noon on the 25th.
Christmas
School Break.
IT IS FURTHER ORDERED that the minor child will be with Father on Father's Day
and Father's birthday. Also, the minor child will be with Mother on Mother's Day and Mother's
birthday. Also, the child's birthday will be split with parents.
IT IS FURTHER ORDERED that when the child is with one parent, the other parent can
call at reasonable times to talk to the minor. Also, the minor can contact either parent, any day at
any reasonable time.
IT IS FURTHER ORDERED that the parents shall follow the following co-parenting
guidelines:
1. The parents shall share information with each other about the child in a timely
manner so as to coordinate and facilitate their parenting together. This
information may include, but is not limited to medical, educational, social,
psychological, and religious aspects of the children's lives.
2. All material, child sharing, court related and financial communications between
the parents shall occur at a time when the child is/are not present or within hearing
range. Communication regarding these issues shall not occur at times of
exchanges of the child or during telephone visits with the child.
3. Neither parent shall say or do anything in the presence or hearing of the child that
Page 2 of 3
would in any way diminish the child's love or affection for the other parent, and
shall not allow others to do so.
4. Should either parent require child care for twenty-four hours or longer when the
child is in his/her care, the other parent shall have first option to provide such
care.
5. Each parent shall always keep the other informed of his/her actual address of
residence, mailing if different, home and work telephone numbers and any
changes within twenty-fours hours of such change occurring.
6. Each parent shall inform the other as soon as possible of all school, sporting and
other special activity notices and cooperate in the child's consistent attendance at
such events. Neither parent shall schedule activities during the other parent's
scheduled parenting time without notice to the other parent.
7. Neither parent shall move the residence of the child out of state or within the state
at a distance of more than 75 miles from the other parent without giving the other
party written notice as required by La R.S. 9:355.1 et seq.
IT IS FURTHER ORDERED that the foregoing stipulations be made the Consent
Judgment of the court, in accordance with Civil Code Article 3071.
The parties do acknowledge receipt of a copy of this Consent Judgment.
JUDGMENT READ, RENDERED AND SIGNED on the 14th day of September ,
2015 at Gretna, Louisiana.
PAUL S. FIASCONARO, Hearing Officer
c~w~.
EDWARD J. BROOKS, JR.
Self-Represented Litigant
Page 3 of 3
Preview
FILED TARRANT COUNTY 8/20/2020 3:59 PM 360-687378-20 THOMAS A. WILDER DISTRICT CLERK JASMIN J. JULIEN § IN THE DISTRICT COURT § V. § JUDICIAL DISTRICT § EDWARD J. BROOKS § TARRANT COUNTY, TEXAS PETITION TO ENFORCE FOREIGN JUDGMENT This Petition to Enforce Foreign Judgment and the attached foreign judgment and declaration are filed under the Uniform Enforcement of Foreign Judgments Act, chapter 35 of the Texas Civil Practice and Remedies Code, by Jasmin J. Julien, Petitioner. The last three numbers of Petitioner's Social Security number are 685. 1. Discovery in this case is intended to be conducted under of rule 190 of the Texas Rules of Civil Procedure. 2. A properly authenticated copy of the Consent Judgment isattached as Exhibit A and is entitled to full faith and credit. 3. The Consent Judgment is final and not subject to modification. 4. Respondent, Edward J. Brooks, has agreed that the child may move to Texas, and Petitioner seeks enforcement. Petitioner prays that this judgment of the 24th Judicial District Court for the Parish of Jefferson of the state of Louisiana be accorded full faith and credit and have the same effect as a judgment of this Court. Respectfully submitted, DWAIN DOWNING 1178 W. Pioneer Parkway ARLINGTON, TX 76013 Tel: (817) 860-5685 Fax: (817) 916-8804 By: ~( Dwainowning ~(2k4 IC J\ State Bar No. 06086550 downingoffice@aol.com Attorney for Jasmin J. Julien Supporting Declaration 1. My name is Dwain Downing. I am above the age of eighteen years, and I am fully competent to make this declaration. The facts stated in this declaration are within my personal knowledge and are true and correct. 2. The last known post office address of Edward J. Brooks is 3300 Dickens Dr. New Orleans, LA 70114. 3. The address of Jasmin J. Julien is 3651 Prairie Waters Dr. #3104, Grand Prairie, TX 75052. 4. The attorney for Jasmin J. Julien is Dwain Downing, 1178 W. Pioneer Parkway, ARLINGTON, TX 76013. ~ D'ah;Downing ~ /' ' \ ~ ~ Attorney for Petitioner My name is Dwain Downing, and I am over the age of 18, and my address is 1178 W. Pioneer Parkway, ARLINGTON, TX 76013, United States. I declare under penalty of perjury that the foregoing is true and correct. Executed in Tarrant County, Texas, on--~---+-· _ _ _ _ _J_v_·+-_2.--c __,_'_')..-...) ___ f:-ry- I ____.c. Dwain Downing, Declarant 24th JUDICIAL DISTRICT COURT FOR THE PARISH OF JEFFERSON STATE OF LOUISIANA NO. 752-066 DIVISION "M" EDWARD BROOKS 0 vs. t~;,-- FILED ~·-~~ ·~t:_ ~~ JAZMINE JULIEN ."~ ~ SEP 14 2015 . :·1 CONSENTJUDGMEN/ ·i~L~ This matter came for hearing officer conference on September 14, 2015 on a motion for Custody and Visitation filed on July 29, 2015 by Edward Brooks. PRESENT: Edward J. Brooks, Jr., Self-Represented Litigant Jasmin J. Julien, erronerously referred to as Jazmine Julien, Self- Represented Litigant When after having a conference with Hearing Officer Paul S. Fiascomrro and with the consent of the parties, IT IS ORDERED that the parties shall be awarded joint custody of the minor child, Cadence P. Brooks, with Jasmin J. Julien being designated as the domiciliary parent. IT IS FURTHER ORDERED that father shall have unsupervised physical custody time with the minor as follows: alternating every three (3) days beginning September 17, 2015 at noon. IT IS FURTHER ORDERED that both parties shall have vacation options with the child each year. They shall notify each other in writing of their vacation plan on or before thirty (30) days prior to departure. Each party shall provide the other with a basic itinerary to include travel dates, destinations and telephone numbers for emergency purposes. Mother and Father shall each have two (2) week each year/summer. IT IS FURTHER ORDERED that the parties agree to the following holiday schedule: New Year Eve In odd years, father will have the minor from noon on the 3 pt until noon on the 1st .In odd years, mother will have the minor from noon on the l 51until noon on the 2nd . New Year Eve In even years, mother will have the minor from noon on the 31st until noon on the 1st In even years, father will have the minor from noon on the 1st until noon on the 2nd . Mardi Gras Even years to mother and odd years to father. I Page 1 of 3 Easter/Spring Odd years to mother and even years to father. July 4th Even years to mother and odd years to father. Labor Day Odd years to mother and even years to father. Halloween Even years to mother and odd years to father. Thanksgiving Day In odd years, Mother will have 8:00 a.m. to 2:00 p.m. and Father will have 2:00 p.m. to 8:00 p.m. In even years, Mother will have 2:00 p.m. to 8:00 p.m. and Father will have 8:00 a.m. to 2:00 p.m. Thanksgiving School Break Christmas Eve In odd years, mother will have the minor from noon on the 24th until noon on the 25 1h. In odd years, father will have the minor from noon on the 25th until noon on the 261h. Christmas Eve In even years, mother will have the minor from noon on the 25th until noon on the 26 1h. In odd years, father will have the minor from noon on the 24th until noon on the 25th. Christmas School Break. IT IS FURTHER ORDERED that the minor child will be with Father on Father's Day and Father's birthday. Also, the minor child will be with Mother on Mother's Day and Mother's birthday. Also, the child's birthday will be split with parents. IT IS FURTHER ORDERED that when the child is with one parent, the other parent can call at reasonable times to talk to the minor. Also, the minor can contact either parent, any day at any reasonable time. IT IS FURTHER ORDERED that the parents shall follow the following co-parenting guidelines: 1. The parents shall share information with each other about the child in a timely manner so as to coordinate and facilitate their parenting together. This information may include, but is not limited to medical, educational, social, psychological, and religious aspects of the children's lives. 2. All material, child sharing, court related and financial communications between the parents shall occur at a time when the child is/are not present or within hearing range. Communication regarding these issues shall not occur at times of exchanges of the child or during telephone visits with the child. 3. Neither parent shall say or do anything in the presence or hearing of the child that Page 2 of 3 would in any way diminish the child's love or affection for the other parent, and shall not allow others to do so. 4. Should either parent require child care for twenty-four hours or longer when the child is in his/her care, the other parent shall have first option to provide such care. 5. Each parent shall always keep the other informed of his/her actual address of residence, mailing if different, home and work telephone numbers and any changes within twenty-fours hours of such change occurring. 6. Each parent shall inform the other as soon as possible of all school, sporting and other special activity notices and cooperate in the child's consistent attendance at such events. Neither parent shall schedule activities during the other parent's scheduled parenting time without notice to the other parent. 7. Neither parent shall move the residence of the child out of state or within the state at a distance of more than 75 miles from the other parent without giving the other party written notice as required by La R.S. 9:355.1 et seq. IT IS FURTHER ORDERED that the foregoing stipulations be made the Consent Judgment of the court, in accordance with Civil Code Article 3071. The parties do acknowledge receipt of a copy of this Consent Judgment. JUDGMENT READ, RENDERED AND SIGNED on the 14th day of September , 2015 at Gretna, Louisiana. PAUL S. FIASCONARO, Hearing Officer c~w~. EDWARD J. BROOKS, JR. Self-Represented Litigant Page 3 of 3